Cuomo FNMA-FHLMC Comment 2

Nebraska Real Property Appraiser Board Commentary Relating to Cuomo FNMA/FHLMC Settlement Agreement & Implementation INDEPENDENT VALUATION PROTECTION INSTITUTE Office location/Parent Entity It is our understanding that many entities have submitted or are submitting proposals to house the new Independent Valuation Protection Institute. As an appraisal regulatory Board, we feel that housing this Institute as part of the Appraisal Foundation, under the Appraisal Subcommittee, would be appropriate. In August 1989 Congress enacted the Financial Institutions Reform, Recovery, and Enforcement Act, better known as FIERRA. Title XI of FIERRA, the “Real Estate Appraisal Reform Amendments,” was specifically targeted at solving appraisal-related problems discussed in Congressional testimony. Title XI required federally regulated financial institutions, such as federally insured banks, thrifts and credit unions, to use State certified or licensed appraisers to perform appraisals in connection with federally related transactions. The relationship established by Title XI created a complementary relationship between the States, the private sector, and the Federal government. Title XI authorized the private sector a private not-for-profit organization, The Appraisal Foundation and its two independent boards, the Appraiser Qualifications Board and the Appraisal Standards Board to establish uniform minimum appraiser qualifications standards and uniform standards ...